OSA Press Release (October 23, 1984)

LOS ANGELES, Oct. 23/PRN – A lawsuit seeking more than $ 20 million in damages
was filed today in Los Angeles Federal Court by two churches of Scientology, charging
that Boxford, Mass., lawyer Michael Flynn; his brother Kevin Flynn; his partner, lawyer
Thomas Hoffman; and other defendants conspired to violate the civil rights of the
churches, according to church attorney Donald C. Randolph.

Randolph charged that the defendants engaged in a “malicious conspiracy” against the
Church of Scientology. Randolph said this included:

– the unlawful communication of knowingly false or misleading information to state and
federal law enforcement agencies;

– numerous false statements against the churches in lawsuits throughout the country; and

– an extensive media campaign to disseminate false information about the churches.

The complaint also alleges that the defendants boasted “of their coordination and close
relationships” with government agents in carrying out their personal vendetta against the
churches.

These agents include representatives of the IRS, the FBI, and the Department of Justice,
who have all been involved in litigation with the church for almost a decade, Randolph
said.

The suit, filed in the U.S. District Court for the Central District of California, asks for
more than $10 million in 9 compensatory damages and $10 million in punitive damages,
Randolph said. The claims were brought based on alleged violations of the Civil Rights
Act of 1871, he continued.

The churches’ 48-page complaint details what Randolph described as “an ongoing
conspiracy, stretching back at last five years.”

Randolph added that “the nature and extent of the conspiracy is documented in full detail
in papers regarding ‘Famco’ (Flynn Associates Management Corp.), a corporation
created by the conspirators to forward their campaign and in numerous other documents,
as well as eyewitness accounts.”

Randolph said, “This broad-based conspiracy undertook to purposely manipulate the state
through unlawful activities and ultimately to destroy a religion.”

Randolph said: “This lawsuit is important for the preservation of religious freedom, not
only for the Scientologists but for people of all faiths who cherish their right to exist and
worship without unlawful interference. This action seeks to terminate the antireligious
activities and to send a warning to their imitators.”

Contact – Donald C. Randolph or Sanford Block at 213-474-6020 and 213-662-9431 for
the Church of Scientology.